United States v. Nkajlo Vangh, 990 F.3d 1138

Nkajlo Vangh, former president of a Hmong credit union, pleaded guilty to bank fraud and received a 90‑month sentence after diverting over $2 million.
He is incarcerated at FMC Rochester and receives regular care at the Mayo Clinic; he is legally blind and deaf and suffers from multiple serious medical conditions (heart issues, diabetes, kidney disease, history of cancer, etc.).
The facility warden initially approved compassionate release and forwarded the request, but the BOP Office of General Counsel declined to file on his behalf.
Vangh filed a pro se compassionate‑release motion under 18 U.S.C. § 3582(c)(1)(A); the district court acknowledged his serious health issues but denied relief because his medical needs were being met and he had not shown an inability to provide self‑care in prison.
Vangh sought an evidentiary hearing and argued the district court failed to determine whether his circumstances were "extraordinary and compelling." He appealed the denial.
The Eighth Circuit affirmed, holding no statutory or supervisory requirement compelled an evidentiary hearing and concluding the district court substantively considered and rejected extraordinary‑and‑compelling reasons.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 3582(c)(1)(A) requires an evidentiary hearing before denying compassionate release	Vangh: a hearing is required when alleged facts, if true, would entitle relief and are not conclusively refuted by the record	Government: statute is discretionary and contains no hearing mandate; courts may not add one under supervisory power	No. The statute contains permissive language; Eighth Circuit declines to impose a hearing requirement.
Whether the district court failed to decide if "extraordinary and compelling" reasons existed	Vangh: court skipped the threshold determination and thus erred	Government: court detailed his conditions and treatments and denied relief because care provided and self‑care ability were sufficient	No. Court adequately considered the conditions and found them insufficient to warrant release; denial not an abuse of discretion.
Applicability of U.S.S.G. §1B1.13 as a policy statement	Parties: assume the policy statement continues to apply	—	Court assumed, without deciding, that §1B1.13 applies and resolved the case on the record.

POM Wonderful LLC v. Coca‑Cola Co., 573 U.S. 102 (statutory text controls interpretation)
Alabama v. North Carolina, 560 U.S. 330 (2010) (courts may not add provisions to a statute)
United States v. Templeton, 378 F.3d 845 (8th Cir. 2004) (statutory interpretation review)
United States v. Williams, 943 F.3d 841 (8th Cir. 2019) (no hearing required under similar First Step Act provision)
United States v. Rodd, 966 F.3d 740 (8th Cir. 2020) (First Step Act procedures and discretionary relief review)
United States v. Loggins, 966 F.3d 891 (8th Cir. 2020) (district court considered and rejected defendant's circumstances)
United States v. Piper, 839 F.3d 1261 (10th Cir. 2016) (out‑of‑circuit decision advocating hearings in certain compassionate‑release contexts)